As the Supreme Court acknowledged with unusual candor in Alabama v. Shelton, a conviction simply is not reliable unless the defendant had access to the guiding hand of counsel and the states case (if not pleaded out) withstood the crucible of meaningful adversarial testing. Alabama v. Shelton, 68 535 U.S. 654, 665 (2002) (quoting Argersinger v. Hamlin, 407 U.S. 25, 40 (1972)).